Members of the Stanford community are responsible for maintaining the highest level of ethical standards as laid out in the University Code of Conduct. This means adhering to applicable laws at all times when transacting University business. Stanford's anti-bribery policy states that all forms of bribery and corruption are absolutely prohibited and clarifies what that actually means.
Anti-bribery policies in most countries make it is illegal to provide, promise or make an offer to provide a foreign government official with anything of value if the offer or payment is made to obtain, retain, or further business activities, regardless of whether the offer is accepted.
Stanford is subject to the US Foreign Corrupt Practices Act (FCPA) and local anti-bribery laws of the country in which the offense occurs. Additionally, because Stanford has a Presence in the United Kingdom (UK), the UK Bribery Act is also enforceable. According to the UK Bribery Act, Stanford and its employees are liable no matter where the bribery occurs.
A government official includes employees of government-owned or affiliated businesses, such as a public hospital or University.
A bribe can be "anything of value," including:
- Cash or cash equivalents such as stock shares
- Gifts or entertainment
- Excess payments / salary to collaborators, designed to influence decisions in Stanford's favor
- Travel payments or reimbursement with low business-to-leisure ratio (e.g., including spouses and family, sightseeing, vacations)
- Political contributions
- Free access to University services, programs, or facilities
- Providing internships or employment to children of government employees or other high-ranking business officials
Personal liability can be imposed upon an individual if that person knows or has reason to know that an improper payment was or is likely to be made or received.
The FCPA can levy fines up to $2 million per violation on Stanford and up to $250,000 on the individual with imprisonment for up to five years per violation. The UK Bribery Act has more drastic consequences, and under the law, Stanford may not pay an employee's fines.
Any action involving a government official, including government-affiliated businesses such as a public hospital or University, should be handled VERY carefully. If you have questions about Stanford's anti-bribery policy or want advice about a situation, contact the Office of General Counsel (OGC).